Plaintiffs, Cara Leslie Alexander, David Lee Black, Marjorie A. Bridgman, and Joseph N. Cate, by counsel and pursuant to Rule 34 of the Federal Rules of Civil Procedure, hereby request that Defendant Hillary Rodham Clinton produce the originals of documents described below within thirty (30) days of service of this notice in the offices of Judicial Watch, Inc, 501 School Street, S.W., Suite 725, Washington, D.C. 20024.

 1.     In producing documents requested herein, you shall produce documents in full, without abridgment, abbreviation or expurgation of any sort.

 2.     All documents shall be segregated in accordance with the numbered and lettered paragraphs and subparagraphs herein.

 3.     All documents requested herein as to which you withhold production on the basis of a claim of privilege or statutory authority shall be listed in accordance with the procedure described in instruction 2 above and shall be identified by:  a) author(s); b) addressee(s); c) date; d) type of document; e) subject matter; f) number of pages; g) number of attachments or appendices; h) indicated or blind copies; i) all persons to whom shown or explained; j) present custodian; and k) factual or legal basis for claimed privilege, or specific statutory authority which provides the claimed base for non-production.
 
4.     All documents requested herein which have been destroyed, placed beyond your control, or otherwise disposed of shall be identified by: a) author(s); b) addressee(s); c) date; d) type of document; e) subject matter; f) number of pages; g) number of attachments or appendices; h) indicated or blind copies; i) all persons to whom distributed, shown or explained; j) date of destruction or other disposition; k) reason for destruction or other disposition; l) person authorizing destruction or other disposition; m) person destroying or otherwise disposing of document; and n) if not destroyed, person in possession of document otherwise disposed of.

1.     The word "document" shall mean any written or graphic matter or other means of preserving thought or expression, and all tangible things from which information can be processed or transcribed, including, but not limited to, correspondence, memoranda, notes, messages, letters, telegrams, teletyped messages, bulletins, diaries, chronological data, minutes, books, reports, charts, ledgers, invoices, worksheets, receipts, computer printouts, schedules, affidavits, contracts, transcripts, surveys, graphic representations of any kind, photographs, graphs, microfilm, video tapes, tape recordings, motion pictures or other film.

2.     "Person" means any natural person or any legal entity, including, but not limited to, a corporation, partnership and unincorporated association, and any officer, director, employee, agent or other person acting or purporting to act on its behalf.
 
3.        "And" and "or" shall be construed disjunctively or conjunctively as necessary in order to bring within the scope of each request all documents which might otherwise be construed to be outside its scope.
 
4.         The term "and/or" is to be read in both the conjunctive and disjunctive and shall serve as a request for information which would be responsive under a conjunctive reading in addition to all information which would be responsive under a disjunctive reading.
 
5.     "Each" includes both "each" and "every."
 
6.     The singular and masculine gender shall, respectively, include the plural and feminine gender, and vice versa.
 
7.     "You" and "your" shall mean yourself and all other persons acting or purporting to act on your behalf.
 
8.     "Relating to" and "relates to" mean, without limitation, relating to, concerning, constituting, mentioning, referring to, describing, summarizing, evidencing, listing, relevant to, demonstrating, tending to prove or disprove, or explain.
 
9.     "Communication" or "communications" includes, without limitation, in-person or telephone conversations, facsimiles, letters, electronic mail, telegrams, telexes, tapes or other sound recordings, or other means of transmitting information from one source to another.
 
10.     "Plaintiffs"- The term "Plaintiffs" refers to Cara Leslie Alexander, David Lee Black, Marjorie A. Bridgman, and Joseph N. Cate, and to all other members of the class described in the Complaint, namely, employees and volunteers in the White House during the Reagan and Bush Administrations whose Federal Bureau of Investigation ("FBI") files, or information contained therein, were turned over without authorization to the White House or individuals therein at any time during the administration of President Clinton.
 
11.     "Defendants" - The term "Defendants" in the context of this case refers to the Federal Bureau of Investigation (FBI), the Executive Office of the President, Hillary Rodham Clinton, Bernard W. Nussbaum, Esq., David Craig Livingstone, and Anthony Marceca.
 
12.     "White House" means both the residence of the President of the United States, located at 1600 Pennsylvania Ave., N.W., Washington, DC; and the Executive Office of the President.
 
13.     These document requests cover the period of time from January 20, 1993 up to the date of your response to them and are continuing, to the extent Rule 26(e) requires.  In the event that any information or any documents come to your attention, possession, custody, or control subsequent to the filing of your responses to these document requests, which materials or information are responsive to any document request, but which were not included in your initial response thereto, please furnish said additional information materials to attorneys for plaintiffs as soon as possible.

1.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any FBI files on former Reagan and Bush administration employees obtained by the White House during the Clinton Administration ("the FBI files"), the contents of those files, the circumstances under which the Clinton White House obtained possession of those files, or any investigation of those circumstances.

2.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with Hillary Clinton regarding the FBI files, their contents, the circumstances under which the Clinton White House obtained possession of those files, or any investigation of those circumstances.

3.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with President Bill Clinton regarding the FBI files, their contents, the circumstances under which the Clinton White House obtained possession of those files, or any investigation of those circumstances.

4.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with any officer, employee or agent of the Democratic National Committee or the Democratic Party regarding the FBI files, their contents, the circumstances under which the Clinton White House obtained possession of those files, or any investigation of those circumstances.

5.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with any  Defendant, or Defendants or with any person or persons initially named as Defendants in this case regarding the FBI files, their contents, the circumstances under which the Clinton White House obtained possession of those files, or any investigation of those circumstances.

6.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any communications with any officer, agent or employee of the FBI regarding the FBI files, their contents, the circumstances under which the Clinton White House obtained possession of those files, or any investigation of those circumstances.

7.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any correspondence or communications with any officer, employee or agent of the Executive Office of the President regarding the FBI files, their contents, the circumstances under which the Clinton White House obtained possession of those files, or any investigation of those circumstances.

8.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to any authority investigating the circumstances under which the Clinton White House obtained possession of the FBI files, including, without limitation, any congressional committee and any office of the United States Department of Justice.

9.     Any and all records, correspondence, notes, communications, and other documents concerning or relating to the circumstances under which D. Craig Livingstone acquired employment at the White House, including, but not limited to, his job description, duties, his qualifications to perform those duties, and any evaluations prepared by anyone about how he performed those duties.

10.    Any and all records, correspondence, notes, communications, and other documents concerning or relating to the detailing of Anthony Marceca by the Department of the Army, to the White House, or the extension of that detail, including, but not limited to, his job description, duties, his qualifications to perform those duties, and any evaluations prepared by anyone about how he performed those duties.

11.    Any and all records, correspondence, notes, communications, and other documents concerning or relating to the appointment of Bernard Nussbaum to a position in the Clinton White House, his duties at the White House, his qualifications to perform those duties, or his performance of those duties.

12.    Any and all records, correspondence, notes, communications, and other documents that concern or relate to any conversations, discussions, requests for advice, or any matter relating to the above-captioned case or the case of Michael John Grimley et al. v. Federal Bureau of Investigation, et al, C.A. No, 97-01288 (D.D.C).

13.     Any and all desk calendars, appointment books, journals, logs, and diaries which concern or relate to the FBI files, the job description, duties, instructions, assignments, or evaluations of Bernard Nussbuam, Tony Marceca, or D. Craig Livingstone.

14.      Any and all records, correspondence, notes, communications, and other documents concerning or relating to the dissemination of the FBI background investigation files and or summary reports to any persons in the White House, to any agencies or entities of the Executive, Legislative, or Judicial Branches of the United States Government, to any foreign governments, and/or to any private person(s) or entity(ies).

15.      Any and all records, correspondence, notes, communications, and other documents concerning or relating to the uses for which the FBI files were put by the White House, by any agencies or entities of the Executive, Legislative, or Judicial Branches of the United States Government, by any foreign governments, and/or by any private person(s) or entity(ies)

16.      Any and all records, correspondence, notes, communications, and other documents produced pursuant to a Congressional subpoena, grand jury subpoena, or a voluntary agreement with the U.S. Department of Justice or other investigatory agency of the United States, including the office of Independent Counsel Kenneth Starr, concerning or relating to the disclosure to White House personnel (including employees, detailees, volunteers, and interns) or by other persons in the White House (including Hillary Rodham Clinton), of FBI background investigation files or summary reports on former Reagan and Bush Administration appointees and employees.

17.     Copies of any subpoena(e) or voluntary agreement(s) for the documents in Request Number 16.

18.     Any and all records, correspondence, notes, communications or other documents which are relevant to the allegations of the complaint, and any and all records, correspondence, notes, communications or other documents which may lead to such relevant evidence.
 
 

      By: ___________________
       Larry Klayman, Esq.
       D.C. Bar No. 334581
       JUDICIAL WATCH, INC.
       501 School St., S.W.
       Suite 725
       Washington, DC 20024
       (202) 646-5172

       Attorneys for Plaintiffs